- Introduction
- Scheme to infiltrate and control "Valley of Lakes"
- Land Development Scheme
- Lake Algonquin Scheme
- Building Fees Scheme
- Real Estate Scheme
- Sewage System Schemes
- Arnold Palmer Golf Course Scheme
- Bank's scheme to conceal insolvency of CBG Ltd.
- Scheme to continue Racketeering using Chapter 11 Bankruptcy protection
- Bank's Scheme to operate and manage the Racketeering Enterprise
- Scheme to conceal Racketeering Activity prior to merger and to continue Pattern of Racketeering Indefinitely
- Enterpise
- Pattern of Unlawful Racketeering Activity
- Summary of each defendant's association with and participation in the pattern of Racketeering Activity
- Summary of each plaintiff's injury to Business or Property
- Count II: Interstate Land Sales Full Disclosure Act
- Count III: Civil Rights Violations
- Count IV: N.J. Real Estate Sales Full Disclosure Act
- Count V: Common Law Fraud and Deceit
SUMMARY OF EACH PLAINTIFF'S INJURY TO BUSINESS OR PROPERTY
364. Plaintiffs LEON R. DONGELEWICZ and MARGARET J. DONGELEWICZ, his wife, purchased LOT NO. D-70, from Joseph Oertel and Martha Oertel, his wife, recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2330, Page 968 to Page 971, (Exhibit 75-1 to 75-4) on or about November 8, 1989 and have resided on the property, and were injured in their business and/or property as a direct result of the pattern of racketeering.
365. Plaintiff FRANCIS X. BURNS purchased LOT NO. 29 on Plat "A", recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2336, Page 1046 to Page 1049 (Exhibit 48-1 to 48-4), on or about January 2, 1989, from Raymond A. Pierce, and was injured in his business and/or property as a direct result of the pattern of racketeering.
366. Plaintiff LAURA BURNS purchased LOT NO. 73 on Plat A, recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1400, Page 134 to Page 137, on or about October 30, 1987, (Exhibit 53-1 to 53-4), from CBG Ltd., and purchased LOT NO. A-22 recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1417, Page 699 to Page 702, on or about October 12, 1988, (Exhibit 51-1 to 51-4), from CBG Ltd., and was injured in her business and/or property as a direct result of the pattern of racketeering.
367. Plaintiff LOIS A. BURNS purchased LOT NO. 84 on Plat J, recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2251, Page 916 to Page 919, on or about November 12, 1987, (Exhibit 43-1 to 43-4), from CBG Ltd., and was injured in her business and/or property as a direct result of the pattern of racketeering.
368. Plaintiffs GEORGE M. DE PERSIA and SHARON M. DE PERSIA, his wife, purchased LOT NO. Z on or about DATE from [and have resided on the property], and were injured in their business and/or property as a direct result of the pattern of racketeering. 68 Lake valley Drive, Valley of Lakes, PA, (Mailing address: P.O. Box 227, Nuremberg, PA 18241).
369. Plaintiffs John B. Knox and BETSY C. KNOX, his wife, purchased LOT NO. 275 on Plat EA, recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1440, Page 761 to Page 764, on or about April 17, 1990, (Exhibit 33-1 to 33-4), from CBG Ltd., and purchased LOT NO. 10 on Plat ER,, recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1468, Page 612 to Page 616, on or about August 26, 1991, (Exhibit 37-1 to 37-4), from CBG Ltd., and were injured in their business and/or property as a direct result of the pattern of racketeering.
370. Plaintiff JOHN T. MIELE, purchased LOT NO. A-19, recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1407, Page 718 to Page 720, (Exhibit 83-1 to 83-3), on or about May 10, 1988, from Paul Malone Associates, and have resided on the property, and was injured in his business and/or property as a direct result of the pattern of racketeering.
371. Plaintiffs FRANK J. RACHUBINSKI and HELEN A. RACHUBINSKI, his wife, purchased LOT NO. A-43 on or about August 15, 1978, and have resided on the property, and were injured in their business and/or property as a direct result of the pattern of racketeering.
372. Plaintiff SENTA M. SHERIDAN purchased LOT NO. CW-81 recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2301, Page 264 to Page 265, on or about February 28, 1989, (Exhibit 57-1 to 57-2) from Charles Bud Crawford and Carol Crawford, his wife, and have resided on the property, and was injured in her business and/or property as a direct result of the pattern of racketeering.
373. Plaintiff GER D. J. SMIT purchased LOT NO. 92 on Plat EA, recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1429, Page 0077 to Page 0080, on or about June 10, 1989, (Exhibit 49-1 to 49- 4) from C.B.G. Limited, and was injured in his business and/or property as a direct result of the pattern of racketeering.
374. Plaintiffs WACLAW SZCZESNIAK and DANUTA SZCZESNIAK, his wife, purchased LOT NO. B-56 on or about April 29, 1989, and have resided on the property, and were injured in their business and/or property as a direct result of the pattern of racketeering.
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